TSCA 30/30: May 10, 2017

Keller and Heckman LLP and Cardno ChemRisk present a webinar series on the changes to the Toxic Substances Control Act (TSCA) resulting from the June 22, 2016 passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act).

May 10, 2017 Topic: Using Exposure Assessment to Mitigate Risk Concerns

Risk assessment involves evaluation of two factors, hazard and exposure.  While it is intuitive that low hazard often means low risk, the same is true for exposure.  Where a manufacturer can show that there is limited or no exposure to potentially exposed people or releases to the environment, the EPA should be able to reach a conclusion that there is sufficient information to reach a “no unreasonable risk” conclusion in evaluating chemicals and uses.  EPA’s prior determinations in establishing various exemptions including the polymer exemption and the exemptions for low volume LVE) and low exposure/low release.  Ken and David discussed the criteria EPA uses in evaluating exposure and made recommendations on how to analyze their utility. 

During this webinar we discussed:
 

• Exposure as a risk assessment parameter – models
• LVE/LoRex Criteria and EPA’s Exemptions
• Examination of LVE/LoRex Criteria
• Factoring Exposure Into New Chemical Submissions